Modern slavery statement

This statement sets out how we deliver our commitment to comply with the Modern Slavery Act 2015 and covers the position on modern slavery for GreenSquareAccord including all subsidiary companies for activities during the period April 2023 to March 2024.

Our operations

GreenSquareAccord is a registered social housing provider of housing, regeneration, Care & Support and commercial services across the West Midlands, Wiltshire, Oxfordshire and surrounding areas with a combined portfolio of approximately 23,000 properties and is regulated by the Regulator of Social Housing (RSH).

We’re proud to be able to support tens of thousands of people across England by providing affordable housing and care to help people live independently.

Everything starts at home, and we are privileged to be able to do work which makes a real difference to the lives of people in our communities. Everything we do is about people – whether that’s providing a good quality, safe home or providing care which helps someone to live an independent life. Our colleagues and board and committee members live and breathe this social purpose.

Supply chain policy

Our supply chains are extensive, consisting of building works, maintenance contractors, service providers and agencies and operating predominantly within the UK. Some suppliers subcontract work or utilise recruitment agencies to supply temporary or permanent staff. By the nature of their businesses some of our suppliers are potentially at higher risk of exposure to modern slavery than others, for example, maintenance, repairs and construction companies, cleaning and grounds maintenance contractors, security firms and specialist managing agents who provide support and/or care.

As part of our new supplier approval procedure, we require our suppliers, delivery partners, organisations within our frameworks and other suppliers we engage with to declare that they will ensure their goods, materials, and labour-related supply chains fully comply with the Modern Slavery Act 2015.

We maintain a register of suppliers and contracts on our supplier portal and new suppliers are asked to confirm compliance with the principles of modern slavery legislation via a Slavery and Human Trafficking Statement when they register on our supplier portal.

Potential suppliers are required to confirm compliance with the annual reporting requirements contained within the Modern Slavery Act 2015 when tendering for contracts with GreenSquareAccord. Modern Slavery offences committed under the Modern Slavery Act 2015 are mandatory exclusion grounds at tender stage and apply to all procurements subject to the Public Contracts Regulations 2015.

During 2023/24 we have reviewed procurement practices to consider the application of the recommended approaches for tackling modern slavery set out by the Government in Procurement Policy Note 02/23 published in February 2023. This review included a review of our contract conditions to ensure appropriate terms and conditions are included as standard.

Recruitment and people management

GSA is committed to being a National Living Wage employer, which means that all colleagues are paid at least the National Living Wage rate as set by the UK Government.

Our recruitment and people management procedures ensure all prospective colleagues are legally entitled to work in the UK and recruitment procedures are managed by a capable and qualified in-house Human Resources Team who ensure robust pre-employment checks are conducted. These include proof of eligibility to work in the UK, employment references, and DBS checks for applicable roles. We only engage with reputable recruitment agencies who are required to demonstrate a commitment to anti-slavery policies and procedures.

All members of staff are provided with e-learning training which covers awareness of modern slavery and how to report suspected abuse. Colleagues must complete this training as part of their induction and at refresher intervals thereafter.

Safeguarding

We are committed to helping adults and children live their lives free of abuse, harm and intimidation. Our safeguarding policies cover modern slavery legislation (encompassing slavery, human trafficking, forced labour and domestic servitude) and set out the robust practices which should be followed and the responsibilities of employees in preventing the abuse or mistreatment of adults and children we work with.

All colleagues in GSA undertake mandatory safeguarding training.

Monitoring effectiveness

During 2024-25 we will continue to ensure we understand the potential risks of modern slavery and human trafficking in delivering our services and managing our supply chain.

We will ensure that the provisions of the Procurement Act 2023 with respect to supplier exclusion grounds are embedded in revised Procurement procedures with effect from 24 February 2025. We will be providing training to procurement and commercial colleagues to ensure new procurements and contracts comply with the Procurement Act 2023, including addressing modern slavery risks in our supply chain.

We will continue to monitor supplier compliance with the Modern Slavery Act via our supplier portal.